Assuming we take those images as canon, there is still plenty of reason to figure the early one was built in orbit.
For one thing, Mars gravity is a shitload less than earth.
24th century tech seems way more advanced than 23rd, so they've probably got new systems in addition to old ones like spacedock.
Plenty of stuff from GR and others indicate that when they were talking about this pre-TMP, that the SF yards were in geosync orbit ABOVE SF, not in the city itself.
Everybody will have 2000 ways to tear all this apart, but I wanted to get on-record and get out before the bombs start falling.
We don't have to assume anything, they appeared in the episode of STNG:
